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Speak Up - Contacts for the Code of Conduct

At Bertelsmann, employees, business partners and third parties always have the opportunity to ask for advice, discuss a concern about potential misconduct or provide suggestions for improving compliance procedures.

The following resources are available for employees as well as third parties:

1. In the Immediate Working Environment

Employees may contact a person in their immediate working environment to discuss questions regarding the Code of Conduct or to report violations; for instance: their supervisor, senior management of their company, the Human Resources, Legal, Finance or Audit departments, or, if applicable, their respective employee representatives.

A key responsibility of the Bertelsmann Integrity & Compliance Department is to support requests relating to the Code of Conduct and to ensure that reports of violations are investigated. Investigations are conducted with the greatest possible regard for confidentiality and in compliance with data protection requirements.

3. Internet-based System

Employees or third parties may also report substantial violations of the Code of Conduct, specifically illegal business practices, using an Internet-based system. The system is available in multiple languages and allows for a confidential and specially encrypted, secure dialog with the Bertelsmann Integrity & Compliance Department.

4. Ombudsperson

Employees or third parties may also contact one of the external ombudspersons appointed by Bertelsmann. The ombudsperson’s role is to provide a neutral and independent channel for inquirers seeking confidential guidance in raising and resolving any suspected substantial violations against the Code of Conduct, especially illegal business practices. The ombudsperson treats all communication with those seeking assistance as confidential, and does not disclose details of the case, including the identity of the inquirer, unless given explicit permission to do so by the inquirer.